In 1988, shortly before he died, Andrei Sakharov commented on the fate of
the
earth. Interestingly enough, rather than comment on the hydrogen bombs
that he
co-invented, he stated: "... in fact, I am now inclined to regard the
many-faceted ecological threat to our environment as our most serious
long-term
problem.1" Because I agree with this very long-term assessment, it is
troubling to me to see environmental funds and political capital wasted
on
false threats. In particular, I am concerned that the quasi-legalistic
concept
of "prudent avoidance" is being used to chase the phantom risk of
cancer caused
by extremely low frequency (ELF) electromagnetic fields (EMF) from
power lines.
This needless chase costs some one to three billion dollars per
year2,3 and
unnecessarily frightens the public with "electrophobia." The burden of
these
fiscal and emotional costs placed on the American public are
incommensurate
with the risk, if any, begin mitigated. This outcome is not a use of
science
for the public good.

What is Prudent Avoidance?

In the absence of any firm scientific demonstrated connection between
ELF/EMF
and cancer, the concept of "Prudent Avoidance" has been invoked by many
utility
commissions (at least eleven by recent count) as a basis for
promulgating
regulations. Granger Morgan defines4 "prudent avoidance" as:
"Prudence means
exercising sound judgement in practical matters. It means being
cautious,
sensible, not rash in conduct." Morgan continues, prudent avoidance
"is to try
to keep people out of fields when that can be done at modest cost --
but not to
go off the deep end with expensive controls which may not be
beneficial."

Prudent avoidance, as thus defined, might seem reasonable if one
understood
the nature and severity of the risk, which is not the case for the
alleged EMF
health hazard. From there Morgan moves towards suggesting the
arbitrary
spending of money without measurable benefits: "Utilities and utility
regulators must consider both distribution systems and transmission
systems.
Activities that may warrant consideration at the distribution level
include:
paying greater attention to population distributions around facilities;
incorporating more consideration of exposure management in maintenance
and
facility upgrade policies... making selected use of undergrounding..."
At this
point "prudent avoidance" becomes imprudent because it leads to an
open-ended,
unbounded approach to risk mitigation. It stimulates a fearful public
to use
the threat of litigation to force utilities and school boards to take
steps to
mitigate a phantom effect. These institutions have little incentive to
risk
litigation, as long as the costs of compliance will be covered by rate
payers
or tax payers.

Morgan's approach appears to be driven by his statement that "there is
some
significant chance that fields pose a modest public health risk, and
not much
chance that the risk to any one of us will be very big.4" In my
analysis of
Morgan's work, he seems to have placed great reliance on the very
questionable
work of Wertheimer and Leeper5 when he stated (1992) that "a series of
epidemiological studies, including studies of childhood leukemia by
Naorgan alludes4 to Thomas Kuhn's STRUCTURES OF SCIENTIFIC
REVOLUTIONS by stating that "paradigm shifts" are affecting "scientific
thinking about biological effects from electric and magnetic fields."
It is
premature to talk of paradigm shifts when the preponderance of the data
does
not demonstrate that there is a connection between cancer and these
fields.
Morgan is concerned that public perceptions may drive regulations
rather than
scientific fact. However, I conclude that it is his own papers that
have
strongly pushed the EMF-risk process away from science and toward
irrationality. I agree with the critics of "prudent avoidance" who
have call
it "the abandonment of science, "the triumph of fear of the unknown
over
reason," and "being so vague as to be useless.4" Prudent avoidance is
a
delight for plaintiff lawyers since it is essentially a conclusion that
the
danger is probable.

The General Accounting Office (GAO) report7, ELECTROMAGNETIC FIELDS,
acknowledges this misuse of science by cont the total economic costs of
the [EMF mitigation]
activities described above now exceed $1 billion annually, with the
promise of
growing costs in the years to come..... If we were to value the
reduction of a
unit of EMF risk at comparable levels, the most that we could justify
spending
on EMF mitigation would be something in the neighborhood of $10 billion
per
year.... Recent examples include a town that moved several blocks of
distribution lines underground at a cost of $20,000 per exposed person;
a
utility that rerouted an existing line around a school at a cost of
$8.6
million; a new office complex that incorporated EMF exposure in its
design at a
cost of $100-200 per worker; and a number of firms that have installed
ferrous
shielding on office walls and floors to reduce magnetic field exposures
from
nearby power handling equipment at costs ranging up to $400 per square
meter of
office space.2"

The GAO study7 estimates the following costs for EMF mitigation, which
would
not reduce the EMF from appliances from within the home.

-- $250 billion to reduce average exposure to less than 2 mG
from all
transmission and distribution lines.

Allan Bromley, President Bush's Science Advisor, recently commented on
an EMF
study done by the Office of Science and Technology Policy: "It is
safe,
however, to conclude that the EMF risk issue will continue to be
contentious
and of immense potential economic importance; the current best estimate
is that
prior to 1993 it has cost the American public more than $23 billion to
respond
to public worries about EMF -- particularly in connection with the
placement of
high-voltage power lines.3"

Recently a law suit was filed against Houston Light and Power and the
Electric
Power Research Institute (EPRI) on behalf of eleven families with
children
suffering from cancer. The suit charges both the power company and
EPRI with
"fraudulent concealment of the carcinogenic nature of the fields that
secretly
and silently invaded their homes." To avoid such litigation and the
associated
unfavorable publicity, other institutions have decided to give in,
rather than
fight. For example: (a) The San Diego Gas and Electric Company
cancelled a
power plant upgrade and compromised on a 69-kV line. (b) Hawaiian
Electric
Industries, Inc., spent nearly $5 million to reroute and reconfigure
power
lines. (c) In the Mill Valley School District, 4 classrooms, a day
care
center, and a part of the playground located near power lines have been
closed.
(d) The policy of prudent avoidance added about $500,000 to the
construction
costs of the World Bank Building, and this approach is now considered
to be a
model in this area. (e) The California Public Utility Commission has
required
the utilities to spend up to 4 percent of the cost of electrical
projects to
mitigate EMF. Thus, we see that the advocates of "prudent avoidance"
are
willing to spend large sums for mitigation efforts with no clear
assessment of
any benefits to be gained.

Evidence Bearing on Effects of EMF.

The scientific literature and the reports of review panels show no
consistent,
significant link between cancer and the EMF from power lines8. This
literature
includes epidemiological studies, research on biological systems, and
the
analyses of theoretical mechanisms. This negative result is consistent
with
the implications of arguments which have been advanced that there can
be no
such link. The preponderance of the epidemiological and
biophysical/biological
research findings have failed to substantiate those studies that have
reported
specific adverse health effects from the exposure to 60-Hz EMFs. It is
always
possible that some minor carcinogenic connection might be found, but
the
present data do not establish that connection. To justify expenditures
on
mitigation, there should be some consistent, meaningful combination of
the
following factors: (a) a plausible coupling mechanism at the cellular
level
exists, (b) evidence that the coupling must produce consistent
biochemical
changes, (c) indications that the biochemical changes must be
detrimental, (d)
meaningful epidemiology data that determine the degree of danger, and
finally,
(e) application of upper-bound mitigation costs for EMF that are
comparable to
the mitigation costs for other dangers in society.

Epidemiology: The scientific panels that have reviewed the EMF
epidemiology
data have found8 them inconsistent and inconclusive. It is necessary
when
comparing the data to separate the results by cancer type. For
example,
consider8 the recent case of three studies of electrical workers and a
recent
study on non-electrical workers in Sweden. The 1993 California study
reported
no association of EMF with either leukemia or brain cancer. The 1993
Canadian-French study reported an association with leukemia, and
astrocytoma,
out of the 32 cancer types studied, but this study suffers from
problems of
internal inconsistencies. The 1995 Savitz/Loomis study reported no
association
of EMF with leukemia, but they reported an association with brain
cancer. The
1993 Swedish study reported an association with leukemia, but not with
brain
cancer. Thus, these four "best studies" report very contradictory
results. It
is very difficult to determine statistically relative risk factors of
less than
two for rare modes of death because of the many confounding factors
such as
economic status and chemical pollutants.

Biology and Biophysics Experiments: The scientific review panels, the
review
articles, and the research papers that we have reviewed8 do not claim a
causal
link between EMF and cancer. In addition, the review panels and review
articles have pointed out that there is a continuing problem with
replicating
the experimental results on cells and animals.

Theoretical Mechanisms: No plausible biophysical mechanism for the
systematic
initiation or promotion of cancer by these extremely weak EMF's has
been
identified8. The lack of epidemiological evidence and experimental
evidence
establishing a link between EMF and cancer is consistent with the
biophysical
calculations that rule out the carcinogenic effects because the thermal
noise
fields are larger than the fields from EMF. Since quantum mechanics,
thermal
noise fluctuations, and cancer promotion are all statistical effects,
it is
difficult to derive a proof that is a necessary and sufficient
condition to
preclude all cancer promotion. However, these fundamental calculations
are a
significant guide post to conclude that the EMF-cancer link, if any,
should be
extremely difficult to detect because its magnitude is, at most, very
small.

Journalism: The number of newspaper stories on EMF rose from 233 in
1992 to
548 in 1993. The number of magazine stories rose from 101 in 1992 to
216 in
1993. The writings of Paul Brodeur, such as CURRENTS OF DEATH, have
been
followed with headlines of "Is My Electric Blanket Killing Me" to
"Chilling
Possibility: That A Power That Has Improved Life Could Also Destroy It"
to
"Warning: Electricity Can be Hazardous to Your Health." Even when an
article
is even-handed, its caption at the top read: "Steps to Protect
Yourself from
Danger -- Real and Potential." It is my conclusion that the science
and
relative risk methodology often undercut quality of journalism in a
free and
fear-prone society.

The statement issued by the Council of the American Physical Society
(APS)
(reprinted in the Comment section) addresses these concerns in more
general
terms.